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5.5 The assessee vehemently assailed the impugned addition on merits. The written submissions of the assessee have been extracted on page nos. 32 to 39 of the impugned order. The prime argument of the assessee was that the office as well as residential remises of the assessee was searched, however, no asset, either moveable or immoveable which was acquired out of undisclosed income was found. Even the addition made for AY 2015-16 was based on unsubstantiated grounds. No material evidence was brought on record by Ld. AO to conclude that the assessee had received alleged incidental charges. Shri K. Srinivasulu denied all the transactions with the assessee at the time of cross-examination which make addition unsustainable. The assessee also contended that the seized note books belonged to a third-party where merely had notings regarding alleged payments made to the assessee and others. However, these notings lack the details of nature of the payment and the purpose of payment. Therefore, there was no corroborative evidence to prove that the payments were made. Mere notings in an unauthenticated document could not form the basis of addition. The assessee relied on the decision of Hon'ble Supreme Court in the case of CBI vs. V.C. Shukla (AIR SC 410) holding that loose sheets and entries in diaries could not be considered as account books of a party. Such entries would not have any evidentiary value. Similarly in Common Cause vs. UOI (77 Taxmann.com 245), it was held that dumb documents which are not part of books of accounts do not possess any evidentiary value and liable to be rejected in toto. Similarly, Mumbai Tribunal, in the case of ITO vs Kranti Impex Pvt. Ltd. (ITA No.1229/Mum/2013) held that when the seized papers were undated having no acceptable narration and do not bear the signature of any party, they are in the nature of dumb documents having no evidentiary value and could not be taken to be the sole basis for determination of undisclosed income of the assessee. The onus would be on revenue to collect cogent evidences to corroborate the nothings therein. Similarly, Chennai Tribunal in the case of M.M. Financers Pvt. Ltd. vs DCIT (107 TTJ Chennai 200) held that no addition could be made on the basis of statement made by third-party and the unsigned agreement and dumb loose slips seized, in the absence of any corroborative material to show payment of any undisclosed consideration by the assessee. 5.6 Regarding the provisions of Sec. 132(4A) and 292C, the assessee submitted that such a presumption would be available only in respect of the person from whom the document is seized and the same could not be used against other persons. The Ld. CIT(A) considered these arguments of the assessee and rendered its findings on para 54 to 73 of impugned order.